This page includes summaries of and links to APPA’s regulatory filings at the Federal Energy Regulatory Commission (FERC), APPA’s comments to the Board of Trustees of the North American Electric Reliability Corporation (NERC), and APPA's filings with other regulatory entities. 

For APPA's comments and filings related to environmental regulations, please see our Environmental Filings page. 

Documents linked within each accordion below are organized by date, with the most recent filing/summary presented first within each category/rule. 

Federal Energy Regulatory Commission (FERC)

North American Electric Reliability Corporation (NERC)

  • Commented on revisions to NERC’s standards process manual and rules of procedure implementing its Modernization of Standards Processes and Procedures initiative. We urged NERC to preserve elected sector representation, clarify executive committee authority, and protect meaningful stakeholder review and input into standards development. October 27, 2026.  Note this is the one with two separate documents.
  • Submitted policy input to the NERC Board urging NERC to prioritize foundational computational-load performance requirements, preserve stakeholder participation during standards process modernization, strengthen the volunteer pipeline for NERC committees, and consider affordability and compliance costs. September 22, 2026.
  • Commented and voted affirmative on NERC’s proposed computational load reliability standards. We generally supporting the standards, and sought clarification on applicability limits, modeling and data-sharing expectations, and monitoring requirements. September 17, 2026.
  • Commented on NERC’s proposed Standing Committee Governance Guidelines. We urged NERC to preserve sector-based elections, shorten committee vacancies, maintain full-committee oversight of executive committee actions, and require supermajority voting to ensure broad cross-sector support. September 3, 2026.
  • Commented on NERC’s 2027 Business Plan and Budget, urging NERC to (1) prioritize affordability concerns, (2) tie spending to measurable performance, and (3) clarify how load growth will impact assessments. July 2026
  • Submitted policy input to the NERC Board regarding its three-year strategic priorities. We emphasized the importance of prioritizing the highest impacts risks and avoiding duplicative investments by leveraging the work of regional entities or governmental entities. June 2, 2026.
  • Submitted policy input to the NERC Board urging NERC to (1) add “affordability” as a strategic priority, (2) use caution when adopting artificial intelligence tools, (3) continue to improve stakeholder participation. January 22, 2026
  • Commented on final recommendations for improving NERC’s standards development process, urging NERC not to eliminate the industry balloting segment for transmission-dependent utilities. December 1, 2025
  • Commented on a white paper on options for improving NERC’s standards development process urging NERC to adopt changes that would streamline feedback processes while maintaining flexibility to address emerging risks. August 26, 2025
  • Submitted policy input to the NERC Board urging that any changes to the standards development process be made with the input and consensus of stakeholders. July 29, 2025
  • Commented on how NERC can improve its standards development process to more efficiently address reliability risks while maintaining the valuable role of stakeholder expertise. June 5, 2025
  • Submitted policy input to the NERC Board supporting NERC’s focus on addressing gas-electric interdependencies, while keeping in mind regional differences when addressing interdependency issues. April 23, 2025
  • Submitted policy input to the NERC Board urging NERC to (1) collaborate with stakeholders to identify reliability gaps associated with large loads, and (2) ensure public power perspectives are reflected in the 2025 ERO Risk Priorities report. January 29, 2025
  • Submitted policy input to the NERC Board urging NERC to (1) explicitly consider affordability for ratepayers in its strategic planning, (2) respect its statutory limitations prohibiting standards from requiring the building or enlarging of facilities, and (3) enhance its compliance monitoring and enforcement efforts to improve flexibility for registered entities and reduce the administrative burdens associated with compliance. July 24, 2024
  • Submitted policy input to the NERC Board focused on the importance of meaningful stakeholder participation in NERC governance (i.e., more interaction between the Board and the Members Representatives Committee, respect for the industry-led standard drafting process, and stronger collaboration between NERC staff and the trade associations). May 2, 2024
  • Submitted policy input to the NERC Board focused on improving stakeholder engagement, improving the efficiency of standards development, and improving NERC's communications. February 5, 2024

Other Filings

Other

  • Commented on the Department of Energy (DOE) request for information on securing the United States bulk power system. We urged DOE to adopt risk-based, practical, cost-conscious requirements that build on, rather than conflict with, existing requirements. October 9, 2026. 
  • Commented on the Department of Energy (DOE) draft 2026 National Transmission Needs Study, which—when finalized—will inform DOE’s designation of National Interest Electric Transmission Corridors (NIETCs) and DOE’s coordination of federal transmission financing and permitting authorities. Comments asked that DOE take care that the study is precise about what it does—and does not—conclude, and offered broader considerations on affordability for DOE as it considers its transmission authorities.

  • Commented opposing as drafted the Federal Communications Commission's proposed prohibition on importing and marketing foreign-produced “military-grade” uncrewed aircraft systems (UAS or drones) and UAS critical components. 

  • Commented on the Federal Aviation Administration’s proposed rule for establishing drone flight restrictions over critical infrastructure. We support the effort, but told the FAA that its proposal would leave most of the grid unprotected, impose undue burdens on electric utilities seeking flight restrictions, and constrain utilities’ ability to use their own drones for maintenance and inspection. August 5, 2026
  • Submitted supplemental comments on the Federal Communication Commission notice on Unleashing American Drone Dominance. We continued to urge the FCC to enable scalable unmanned aircraft systems (UAS) deployment while protecting critical infrastructure and aviation safety. May 28, 2026.
  • Commented on the Federal Communication Commission notice on Unleashing American Drone Dominance. We urged the FCC to prioritize policies that enable utilities to deploy unmanned aircraft systems (UAS) safely and at scale through appropriate spectrum access and regulatory certainty. May 1, 2026
  • Commented on the Federal Aviation Administration’s supplemental request for information regarding unmanned aircraft systems beyond visual line of sight operations.  We urged the FAA to ensure safety and avoid collisions by adopting technology requirements that allow cooperative detectability where every aircraft can detect and be detected. February 11, 2026
  • Commented on the Department of Energy’s Speed to Power Initiative. We described the important role that public power utilities play in serving new artificial intelligence data centers, and identified barriers that constrain the ability of public power utilities to expand their capacity to serve new loads while protecting their existing customers from undue costs and risks. November 21, 2025
  • Commented on the Federal Aviation Administration’s proposed rule to normalize unmanned aircraft systems beyond visual line of sight operations.  We supported the FAA’s efforts to facilitate grater drone usage, and urged specific improvements to the rule that would tailor the rule for the electric utility sector because of our industry’s distinctive characteristics and central role in supporting the nation’s economy and security. October 6, 2025

CISA